Jurisdiction: United States
Effective Date: 05/22/2023
Last Updated: 05/24/2025
1. Overview
Mercy House For Relief (“Mercy House”, “we”, “our”, or “us”) is a nonprofit organization operating under U.S. jurisdiction and committed to providing humanitarian and charitable services ethically and legally. This policy outlines our approach to:
- Ensuring compliance by all users and donors
- Preventing violations of U.S. economic sanctions laws
- Complying with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations
2. Scope
This policy applies to:
- All users of the Mercy House website and digital platforms
- All donors, whether individuals or institutions
- All Mercy House staff, volunteers, and third-party processors
- All financial and non-financial transactions
3. User Compliance Policy
3.1 Acceptable Use
Users and donors must:
- Provide truthful and complete personal and financial information
- Use our website only for legal, charitable, and non-commercial purposes
- Comply with all applicable U.S. federal, state, and local laws
3.2 Prohibited Conduct
Users and donors may not:
- Attempt to launder funds through donations
- Use false identities or conceal the source of funds
- Make donations or transactions on behalf of sanctioned or anonymous third parties
- Contribute funds derived from illegal activity
Mercy House reserves the right to suspend, refuse, or refund any donation that violates this policy.
4. Sanctions Compliance Policy
Mercy House complies with the economic and trade sanctions administered and enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).
4.1 Screening
We screen all donors, transactions, and counterparties against:
- OFAC’s Specially Designated Nationals (SDN) List
- OFAC’s Consolidated Sanctions List
- Other applicable government watchlists
4.2 Prohibited Jurisdictions
Mercy House does not accept donations from or conduct financial activity with individuals, entities, or banks located in:
- Iran
- North Korea
- Syria
- Cuba
- Russia (subject to certain restrictions)
- Crimea, Donetsk, and Luhansk regions of Ukraine
- Any other jurisdiction under comprehensive U.S. sanctions
4.3 Sanctions Violations
Suspected sanctions violations will be reported to OFAC or relevant enforcement authorities.
5. Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy
Mercy House complies with the Bank Secrecy Act (BSA), the USA PATRIOT Act, and regulations enforced by the Financial Crimes Enforcement Network (FinCEN).
5.1 Know Your Donor (KYD)
We collect identifying information from donors to assess risk and ensure transparency. Information may include:
- Full legal name
- Contact information
- Billing address
- Payment method and source of funds
Donors making large or suspicious contributions may be asked for further verification (e.g., government-issued ID, proof of income).
5.2 Monitoring and Risk Detection
Mercy House monitors for suspicious behaviors, including:
- Large or structured donations (e.g., just under $10,000 thresholds)
- Anonymous or third-party donations
- Recurring donations from high-risk jurisdictions
- Use of cryptocurrencies or prepaid instruments
5.3 Reporting Suspicious Activity
When appropriate, Mercy House may file a Suspicious Activity Report (SAR) with FinCEN, including:
- Suspicion of money laundering or fraud
- Donations that may be linked to terrorism
- Contributions from high-risk individuals or organizations
5.4 Recordkeeping
We retain donation records and related correspondence for a minimum of five (5) years as required under federal law. This includes:
- Donor identification
- Transaction details
- Risk assessments
6. Roles and Responsibilities
6.1 Compliance Officer
Mercy House appoints a designated Compliance Officer who is responsible for:
- Implementing this policy
- Monitoring donations and users for compliance
- Managing training for staff and volunteers
- Liaising with legal authorities, OFAC, and FinCEN when necessary
6.2 Staff and Volunteers
All relevant personnel must:
- Complete annual AML/CTF and sanctions compliance training
- Report suspected violations immediately to the Compliance Officer
7. Enforcement and Disciplinary Measures
Violations of this policy may result in:
- Rejection or reversal of donations
- Suspension or termination of user accounts
- Cooperation with law enforcement and regulatory bodies
- Civil or criminal penalties as applicable under U.S. law
8. Policy Review
This policy will be reviewed annually and updated in response to:
- Regulatory changes
- New OFAC guidance
- Emerging risks or patterns
9. Contact Information
For questions or concerns about this policy, or to report suspicious activity, please contact:
Compliance Officer
Mercy House For Relief
Email: info@mercyhouseforrelief.com
Phone: (773) 747-7348
Website: https://www.mercyhouseforrelief.org
By using our website or making a donation, you agree to comply with this User Compliance, Sanctions, and AML/CTF Policy.
